Case Digest (G.R. No. 47012)
Facts:
This case involves Lorenzo Alejandrino (recurente) as the petitioner against Benigno Aquino and Ricardo Lopez (recurridos). The events leading to the dispute began on January 2, 1932, when Ricardo Lopez filed a request to purchase a parcel of land designated as Lot No. 5077 in Gunot, Rizal, Santiago, Isabela. However, his application was initially put on hold due to his failure to provide the necessary information to the Director of Lands. Once this information was supplied, his application was reinstated, and an investigation was mandated. On January 8, 1935, Lorenzo Alejandrino submitted his own application to purchase part of Lot No. 5077, as well as a homestead application for the same lot on January 30 of that same year. On March 27, 1935, Ricardo Lopez protested against Alejandrino's applications. In response to this situation, the Director of Lands ordered an investigation, which revealed that Lopez's application related to a certain portion of Lot 5077, while Ale
Case Digest (G.R. No. 47012)
Facts:
- On January 2, 1932, Ricardo Lopez presented a purchase request for a lot marked with No. 5077 situated in the site of Gunot, Barrio Rizal, Santiago, Isabela, directed to the Director of Lands.
- Due to the initial negligence of Ricardo Lopez in submitting certain required information, his application was initially over-seased; however, once the necessary details were furnished, the request was restored and subjected to further investigation.
Background and Initial Applications
- On January 8, 1935, Lorenzo Alejandrino filed his own request to purchase a part of what is described as the same lot (with reference numbers involving Lot No. 5071 or the portions of Lot No. 5077).
- On January 30, 1935, Lorenzo Alejandrino further submitted a request to have a portion of the same lot designated as homestead, thereby asserting his claim to different portions of the property.
Subsequent Requests and Conflicting Interests
- On March 27, 1935, Ricardo Lopez lodged a protest against the requests filed by Lorenzo Alejandrino regarding the disputed portions of the lot.
- The Director of Lands subsequently conducted an investigation to resolve the conflict:
Protest and Initial Determination
- Based on the investigation’s findings, the Director of Lands initially ruled in favor of Ricardo Lopez by approving his purchase request and rejecting those of Lorenzo Alejandrino, reasoning that Lopez’s application and occupation of the lot predated Alejandrino’s.
- At the petition of Lorenzo Alejandrino, the initial decision was set aside, prompting a fresh investigation. Following the new inquiry, the Director of Lands amended his decision and approved Lorenzo Alejandrino’s request with respect to Portions B and C.
Administrative Decisions
- Dissatisfied with the amended decision, Ricardo Lopez escalated the matter by appealing to the Secretary of Agriculture and Commerce.
- Upon review, the Secretary revoked the second (amended) decision of the Director of Lands and reinstated the first decision, holding that the request and occupation by Ricardo Lopez were clearly antecedent to those of Lorenzo Alejandrino.
- Lorenzo Alejandrino then filed a petition for certiorari before the Supreme Court, contending that the Secretary had exceeded his jurisdiction by reversing the Director’s amended decision and confirming the original one.
Appeal to the Secretary of Agriculture and Commerce
- The Secretary’s actions were premised on provisions of Section 3 of Law No. 2874 and Section 3 of Commonwealth Act No. 141, which vest in the Secretary the final authority over the disposition of public lands.
- The administrative record affirmed that Ricardo Lopez’s submission and occupation of the lot occurred prior to those of Lorenzo Alejandrino.
Statutory Framework and Final Findings
Issue:
- Whether the Honorable Secretary of Agriculture and Commerce exceeded his jurisdiction in revoking the Director of Lands’ second (amended) decision and confirming the first decision.
Jurisdictional Authority
- Whether the evidence sufficiently established that Ricardo Lopez’s request and occupation of the property predated Lorenzo Alejandrino’s applications.
Chronology and Precedence of Occupation
- Whether the administrative findings—based on the investigation by the Director of Lands—are final and conclusive following the statutory framework governing public lands.
Validity and Finality of Administrative Findings
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)